Privacy Policy
1. Introduction
Privacy by Design and Commitment to Data Protection
AI2L is committed to protecting the privacy rights of data subjects and implementing privacy-protective measures at every stage of our AI-powered market research platform. We are an AI deep market research platform built on advanced artificial intelligence technologies to provide comprehensive market analysis and business intelligence services.
"AI2L," "we," and "us" refer to Artificial Intelligence to Leads. We offer AI-driven market research analytics services utilising cutting-edge artificial intelligence models, web browsing capabilities, and data reasoning across multiple LLM providers. In this policy, we refer to all these products, together with our other services and websites, as "Services."
This policy covers data we collect when you use our services or communicate with us, including visiting our website, using the AI2L platform, downloading materials, responding to our communications, and attending our events. It also explains your rights regarding your data and outlines our approach to responsible AI development and deployment.
Important Notice about AI-Related Privacy Risks
The use of artificial intelligence technologies in our services presents unique privacy considerations and potential risks that we are committed to addressing transparently:
- AI Model Training: Our AI systems may process personal data during training and inference phases
- Data Inference Risks: AI models may potentially infer sensitive information about individuals from non-sensitive inputs
- Algorithmic Decision-Making: Our services may involve automated decision-making that could affect individuals
- Cross-Border Data Transfers: AI processing may involve data transfers to jurisdictions with different privacy protections
We implement comprehensive technical and organisational measures to mitigate these risks while providing innovative AI services.
Data Protection and Contact Information
For privacy inquiries, data subject rights requests, or concerns about our AI systems, contact our responsible staff at: home@ai2l.app
Brief Overview: Data We Collect and Legal Basis for Processing
| Data Category | Legal Basis (GDPR Art. 6) | Purpose |
|---|---|---|
| Contact details (name, email, phone) | Consent, Contract | Customer support, service delivery |
| Technical data (IP address, device ID) | Legitimate interest, Consent | Website security, analytics, AI model improvement | |
| AI interaction data (prompts, queries) | Contract, Legitimate interest | Service provision, AI model enhancement |
| Marketing preferences | Consent | Sending promotional content |
| Payment and billing information | Contract, Legal obligation | Processing transactions |
| AI-generated insights and outputs | Contract, Legitimate interest | Service delivery, model improvement |
We process this data only when necessary and in compliance with applicable laws, including specific AI governance requirements.
AI Acceptable Use and Prohibited Practices
Our AI services must be used in accordance with our Section 6 AI Acceptable Use Policy and are subject to the following fundamental restrictions based on emerging AI regulations:
Prohibited AI Uses:
- Social scoring or evaluation of individuals based on social behaviour
- Emotion recognition for workplace surveillance (except for safety purposes)
- Subliminal or manipulative techniques designed to distort behaviour
- Exploitation of vulnerabilities related to age, disability, or economic situation
- Real-time biometric identification in public spaces for surveillance
- Generating content that violates intellectual property rights
- Creating deepfakes or synthetic content intended to deceive
For detailed guidance, see our AI Responsible Use Guidelines.
Data Retention Policy
We retain personal data only as long as necessary for the specified purposes. AI training data and model parameters are subject to special retention considerations to balance service improvement with privacy rights.
Cookie Policy & Tracking Technologies
We use cookies and similar technologies for analytics, AI model improvement, and user experience enhancement. We obtain explicit opt-in consent before setting non-essential cookies and provide easy-to-use cookie management tools.
Data Transfers Outside the EEA
We transfer data to service providers in the United States, where our cloud infrastructure and AI model providers operate. We ensure GDPR compliance through:
- Data Processing Agreements and Standard Contractual Clauses (SCCs)
- Technical safeguards, including encryption and access restrictions
- Regular assessments of destination country legal frameworks
Your Rights Under GDPR, CCPA, and AI-Specific Rights
| Rights | GDPR (EU Users) | CCPA (California Users) | AI-Specific Rights |
|---|---|---|---|
| Access data | ✅ Yes | ✅ Yes | ✅ AI decision explanations |
| Rectification | ✅ Yes | ✅ Yes | ✅ Correct AI inferences |
| Erasure | ✅ Yes | ✅ Yes | ✅ Remove from AI models* |
| Object to AI processing | ✅ Yes | ❌ No | ✅ Opt-out of AI decisions |
| Human review of AI decisions | ✅ Yes | ❌ No | ✅ Request human oversight |
*Note: Complete removal from trained AI models may not always be technically feasible. We will provide transparency about limitations.
To exercise your rights, contact: home@ai2l.app
Security Measures for AI Systems
We implement comprehensive security measures for our AI infrastructure:
- End-to-end encryption for AI data processing
- Secure model hosting and access controls
- Regular AI security audits and penetration testing
- Differential privacy techniques where applicable
- Model robustness testing against adversarial attacks
Children's Privacy and AI
Our AI services are not intended for individuals under 16. We implement age verification measures and will promptly delete any data from minors discovered in our systems.
If you do not agree with this policy, including our AI data processing practices, please do not access or use our services.
2. AI Platform Data Processing
2.1 AI Model Infrastructure and Data Flow
Our AI2L platform operates on a sophisticated AI chain built on n8n.io infrastructure, hosted on Hetzner servers, and integrated with multiple AI model providers:
Core AI Stack:
- Platform: n8n.io (self-hosted on Hetzner infrastructure)
- Primary Models:
- Google Gemini 2.5 Pro (Privacy Policy)
- Google Gemini 2.5 Flash (Privacy Policy)
- OpenAI GPT-4o (Privacy Policy)
- OpenAI o1-mini-deep-research (Privacy Policy)
- OpenAI o1-deep-research (Privacy Policy)
Data Categories Processed by AI Systems:
- User queries and prompts submitted to AI models
- Market research requests and parameters
- Generated AI responses and insights
- Web browsing data and search results
- Business intelligence outputs and recommendations
- User interaction patterns with AI systems
2.2 AI Data Processing Purposes and Legal Basis
Service Provision (Legal Basis: Contract - GDPR Art. 6(1)(b))
- Processing user queries through AI models
- Generating market research insights and recommendations
- Providing personalised business intelligence
- Maintaining service functionality and availability
AI Model Improvement (Legal Basis: Legitimate Interest - GDPR Art. 6(1)(f))
- Enhancing AI model accuracy and performance
- Developing new AI capabilities and features
- Quality assurance and error correction
- Bias detection and mitigation
Note on AI Model Training: We do not use personal data for training foundational AI models unless explicitly consented to by users. Our legitimate interest processing focuses on improving service quality and user experience.
2.3 Third-Party AI Model Providers
Google Gemini Models
- Data Processing: Prompts and responses are processed according to Google Workspace privacy commitments
- Retention: Google does not retain prompts or responses after the session ends for business users
- Training: Your data is not used for AI model training without permission
- Privacy Policy: Gemini Apps Privacy Hub
OpenAI Models
- Data Processing: Business data processed under OpenAI's Data Processing Agreement
- Retention: Maximum 30 days for abuse monitoring, then deleted
- Training: Business data is not used for model training unless explicitly opted in
- Privacy Policy: OpenAI Privacy Policy
2.4 AI Data Retention and Deletion
AI Interaction Data: 6 months from last interaction
AI-Generated Insights: Retained for service provision duration as specified in service agreements
Model Training Data: Processed under specific consent or legitimate interest, with regular review cycles
Error Logs and Debugging Data: 90 days maximum
2.5 AI-Specific Data Subject Rights
Right to Explanation: You may request information about how AI decisions affecting you were made
Right to Human Review: You may request human oversight of significant automated decisions
Right to Object to AI Processing: You may object to automated decision-making at any time
Right to AI Data Portability: You may request AI-generated insights in a machine-readable format
3. Website Analytics and Cookies
3.1 Data Categories Collected
We collect analytics data to improve our AI services and user experience:
- Cookies and similar tracking technologies
- Usage patterns and user behaviour analytics
- Website performance and interaction metrics
3.2 Analytics Partners
HubSpot Analytics
- Purpose: Customer relationship management and analytics
- Data: Contact interactions, marketing engagement, service usage
- Privacy Policy: HubSpot Privacy Policy
3.3 Cookie Consent and Management
We implement GDPR-compliant cookie management with:
- Explicit opt-in consent for non-essential cookies
- Granular cookie category controls
- Easy withdrawal of consent mechanisms
- Regular cookie audit and documentation
Cookie Categories:
- Strictly Necessary: Essential for website functionality
- Analytics: Website performance and usage analytics
- Marketing: Personalised content and advertising
- AI Enhancement: Improving AI service recommendations (optional)
3.4 Legal Basis and Retention
Legal Basis: Legitimate Interest (GDPR Art. 6(1)(f)) for essential analytics, Consent for marketing and AI enhancement cookies
Retention Period: 7 years for website analytics data
Your Controls: You can manage cookie preferences through our cookie management interface
4. Customer Relationship Management
4.1 CRM Data Processing with AI Enhancement
Our customer relationship management integrates traditional CRM with AI-powered insights:
Data Categories:
- Contact information and business details
- Communication history and preferences
- Service usage patterns and AI interaction logs
- AI-generated customer insights and recommendations
- Predictive analytics for customer success
4.2 CRM Platform Integration
HubSpot CRM
- Purpose: Customer relationship management with AI enhancement
- AI Features: Predictive lead scoring, automated communication insights
- Data Processing: Contact management, interaction tracking, AI-powered recommendations
- Privacy Policy: HubSpot Privacy Policy
Apollo.io Integration
- Purpose: Enhanced lead intelligence and market research data
- Data Processing: Business contact enrichment, market intelligence
- Privacy Policy: Apollo.io Privacy Policy
4.3 AI-Enhanced Customer Analytics
We use AI to analyse customer interactions and provide improved services:
- Automated sentiment analysis of communications
- Predictive customer success modelling
- Personalised service recommendations
- Intelligent lead qualification and scoring
Legal Basis: Contract performance and legitimate business interests
Opt-out: Customers can opt out of AI-enhanced analytics while maintaining basic CRM functionality
5. Infrastructure and Hosting
5.1 Cloud Infrastructure and Data Processing
Hetzner Cloud Hosting
- Location: Germany (EU) and Finland (EU) data centres
- Purpose: Secure hosting of the AI2L platform and data processing
- Data Processing Agreement: Standard Contractual Clauses implemented
- Privacy Policy: Hetzner Privacy Policy
n8n.io Platform
- Deployment: Self-hosted on Hetzner infrastructure
- Purpose: AI workflow automation and data processing orchestration
- Data Control: Full data control is maintained within the EU infrastructure
- Privacy Documentation: n8n Privacy Policy
5.2 Data Security Measures
Technical Safeguards:
- AES-256 encryption for data at rest
- TLS 1.3 encryption for data in transit
- Multi-factor authentication for system access
- Regular security audits and penetration testing
- Intrusion detection and monitoring systems
- Automated backup and disaster recovery procedures
Administrative Controls:
- Role-based access controls with the principle of least privilege
- Regular employee privacy and security training
- Incident response procedures and breach notification protocols
- Vendor security assessments and ongoing monitoring
5.3 International Data Transfers
EU to US Transfers: When using US-based AI model providers (OpenAI), we implement:
- Standard Contractual Clauses (SCCs) as approved by EU authorities
- Additional technical safeguards, including encryption and access controls
- Regular adequacy assessments of destination country legal frameworks
- Data minimisation practices to limit transfer necessity
6. AI Acceptable Use Policy
6.1 Acceptable AI Service Usage
Permitted Uses:
- Market research and business intelligence gathering
- Data analysis and insight generation for legitimate business purposes
- Automated content summarisation and analysis
- Competitive research within legal and ethical boundaries
- Business process optimisation and decision support
Required Practices:
- Ensure input data accuracy and relevance
- Respect intellectual property rights in AI-generated content
- Use AI insights as decision support, not a replacement for human judgment
- Comply with applicable industry regulations and standards
- Report suspected AI system errors or biases promptly
6.2 Prohibited AI Platform Usage
Strictly Prohibited Activities:
Unlawful or Harmful Content Generation:
- Creating content that violates laws, regulations, or third-party rights
- Generating misleading, false, or deceptive information
- Producing content that promotes illegal activities or services
- Creating deepfakes or synthetic media intended to deceive
Privacy and Data Violations:
- Processing personal data without an appropriate legal basis
- Attempting to identify individuals from anonymised datasets
- Generating profiles of individuals without consent
- Using AI to circumvent privacy protections or consent mechanisms
Discrimination and Bias:
- Using AI systems to discriminate against protected classes
- Implementing biased algorithms in decision-making processes
- Creating or perpetuating unfair treatment based on demographic characteristics
- Ignoring known algorithmic biases without mitigation efforts
Surveillance and Monitoring:
- Real-time biometric identification for surveillance purposes
- Emotion recognition for employee monitoring (except safety applications)
- Social scoring or behavioural evaluation systems
- Unauthorised monitoring of individuals' activities or communications
Market Manipulation:
- Using AI to manipulate market prices or conditions
- Creating artificial demand or supply through automated systems
- Generating fake reviews, testimonials, or social media engagement
- Coordinating market activities to mislead other participants
6.3 AI Governance and Oversight
Human Oversight Requirements:
- Significant business decisions must maintain human review capability
- AI-generated insights should be validated by qualified personnel
- Users must be able to identify AI-generated vs. human-created content
- Clear escalation procedures for AI-related concerns or errors
Compliance Monitoring:
- Regular audits of AI system outputs for bias and accuracy
- Ongoing assessment of AI decision-making fairness
- Documentation of AI system capabilities and limitations
- Incident reporting and corrective action procedures
User Responsibilities:
- Users are responsible for the lawful use of AI services
- Input data must be provided lawfully and with appropriate rights
- Users must respect output accuracy limitations and verify critical information
- Suspected misuse or system errors must be reported promptly
6.4 Enforcement and Violations
Violation Response:
- Warning and corrective action for minor violations
- Service suspension for repeated or serious violations
- Account termination for severe violations or legal non-compliance
- Reporting to authorities when required by law
Appeals Process:
Users may appeal enforcement actions by contacting our AI Ethics Review Board at: ai-ethics@ai2l.app
7. Data Subject Rights and AI Transparency
7.1 Enhanced Rights for AI Processing
In addition to standard GDPR rights, we provide enhanced protections for AI-related processing:
Right to AI Explanation:
- Meaningful information about AI decision-making logic
- Explanation of automated decision significance and consequences
- Information about data sources and processing methods used
- Limitations and accuracy measures of AI systems involved
Right to Human Review:
- Request human intervention in automated decision-making
- Challenge AI-generated decisions that significantly affect you
- Access to qualified personnel for AI-related concerns
- Override procedures for AI recommendations when appropriate
Right to AI Data Correction:
- Correct personal data used in AI model training
- Update preferences affecting AI personalisation
- Request removal of biased or incorrect AI-generated profiles
- Notification of AI model updates affecting your data
7.2 AI Transparency Measures
Model Documentation:
We maintain documentation of our AI systems, including:
- Purpose and intended use of each AI model
- Data sources and training methodologies
- Known limitations and potential biases
- Accuracy measures and performance metrics
- Update frequency and change management procedures
Algorithmic Auditing:
- Regular bias testing across protected characteristics
- Performance monitoring for fairness and accuracy
- Third-party algorithmic audits annually
- Public reporting of aggregate AI system performance
7.3 Exercising Your Rights
Contact Methods:
- Email: privacy@ai2l.app
- Data Protection Officer: dpo@ai2l.app
- AI Ethics concerns: ai-ethics@ai2l.app
Required Information:
To process your request efficiently, please provide:
- Your full name and contact information
- Specific AI service or interaction involved
- Nature of your request and desired outcome
- Relevant dates and reference information
- Verification of your identity (two forms of ID may be required)
Response Timeframes:
- Standard requests: Within 30 days
- Complex AI-related requests: Up to 90 days with explanation
- Urgent privacy concerns: Within 72 hours, acknowledgement
- AI explanation requests: Within 14 days
8. Data Security and AI System Protection
8.1 AI-Specific Security Measures
Model Protection:
- Secure model hosting with encrypted storage
- Access controls preventing unauthorised model modification
- Version control and rollback capabilities for AI models
- Protection against model extraction and reverse engineering
Training Data Security:
- Encrypted storage of training datasets
- Access logging and audit trails for training data
- Data anonymisation and pseudonymization techniques
- Secure deletion procedures for expired training data
Inference Security:
- Real-time monitoring of AI system inputs and outputs
- Detection of adversarial attacks and prompt injection attempts
- Rate limiting and abuse prevention mechanisms
- Output filtering for sensitive information disclosure
8.2 Incident Response for AI Systems
AI-Specific Incidents:
- Biased or discriminatory AI outputs
- Unauthorised disclosure of training data
- AI system manipulation or adversarial attacks
- Model performance degradation or errors
- Privacy violations in AI-generated content
Response Procedures:
- Immediate containment and system isolation
- Assessment of affected individuals and data
- Corrective measures and system updates
- Notification to affected parties within 72 hours
- Regulatory reporting as required by law
- Post-incident review and prevention measures
8.3 Regular Security Assessments
AI Security Auditing:
- Quarterly vulnerability assessments of AI infrastructure
- Annual third-party security audits, including AI systems
- Continuous monitoring of AI model behaviour and outputs
- Regular penetration testing of AI service endpoints
Compliance Verification:
- GDPR compliance audits, including AI processing activities
- AI governance framework assessments
- Third-party privacy certifications and validations
- Regular updates to security measures based on emerging threats
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9. International Data Transfers and AI Models
9.1 Cross-Border AI Processing
Our AI services involve international data transfers to access advanced AI capabilities:
Primary Transfer Destinations:
- United States: OpenAI model processing, Google Cloud AI services
- European Union: Primary data hosting and processing (Germany)
- Other regions: As required for specific AI model access
Transfer Safeguards:
- Standard Contractual Clauses (SCCs) for all international transfers
- Additional contractual protections for AI-specific processing
- Technical measures, including encryption and access controls
- Regular adequacy assessments and due diligence
9.2 AI Model Provider Compliance
OpenAI (United States):
- Data Processing Agreement with Standard Contractual Clauses
- Business data not used for model training without opt-in
- 30-day maximum retention for abuse monitoring
- Enterprise-grade security and privacy protections
Google Gemini (United States):
- Google Workspace enterprise privacy commitments
- No retention of prompts/responses after session end
- Data not shared outside organisation without permission
- Robust access controls and audit capabilities
9.3 Data Localisation Options
For customers requiring data localisation:
- EU-only processing: Available for core platform functionality
- Regional model deployment: Limited AI capabilities with local models
- Hybrid arrangements: Critical data kept in the EU, non-sensitive data for AI enhancement
- Custom solutions: Tailored data residency requirements
10. Updates and Changes to AI Privacy Practices
10.1 Policy Updates and Notifications
Update Triggers:
- Changes to AI model providers or capabilities
- New AI privacy regulations or guidance
- Material changes to data processing practices
- Security incidents requiring policy adjustments
- User feedback and privacy enhancement opportunities
Notification Methods:
- Email notification to registered users
- Website banner and in-platform notifications
- Updated policy with change highlighting
- Direct communication for material changes affecting rights
10.2 AI Technology Evolution
As AI technology rapidly evolves, we commit to:
- Regular review of privacy practices against emerging standards
- Proactive adoption of privacy-enhancing AI technologies
- Engagement with regulatory authorities on AI privacy guidance
- Participation in industry privacy and AI ethics initiatives
- Transparent communication about AI capability changes
10.3 User Control and Consent Management
Ongoing Consent:
- Regular reconfirmation of AI processing preferences
- Granular controls for different AI service features
- Easy opt-out mechanisms for AI enhancements
- Clear communication about new AI capabilities requiring consent
Preference Management:
Users can access and modify their AI privacy preferences through:
- Account settings dashboard with AI-specific controls
- Email preference centre with AI communication options
- Customer service team for complex preference changes
- Self-service privacy tools for common requests
11. Contact Information and Regulatory Authorities
11.1 Privacy and AI Ethics Contacts
Data Protection Officer:
- Email: dpo@ai2l.app
AI Ethics and Responsible AI:
- Email: ai-ethics@ai2l.app
- Escalation procedures for AI-related concerns
- Regular office hours for AI ethics consultations
General Privacy Inquiries:
- Email: privacy@ai2l.app
- Response commitment: 5 business days for initial response
- Comprehensive response within 30 days
11.2 Regulatory Authority Information
For EU Residents:
If you believe we have not adequately resolved your privacy concerns, you may file a complaint with your local data protection authority. Contact information for EU data protection authorities is available at:https://edpb.europa.eu/about-edpb/about-edpb/members_en
For California Residents:
California residents may contact the California Attorney General's office regarding privacy concerns:https://oag.ca.gov/contact/consumer-complaint-against-business-or-company
For Other Jurisdictions:
We will provide specific regulatory contact information based on your location upon request.
11.3 Emergency Contact Procedures
Privacy Incidents:
For urgent privacy concerns or suspected data breaches:
- Emergency Email: privacy-emergency@ai2l.app
- 24-hour response commitment for critical incidents
- Escalation to senior management and legal counsel
AI Safety Concerns:
For AI system safety or ethical concerns:
- Immediate reporting: ai-safety@ai2l.app
- Direct escalation to AI Ethics Review Board
- Coordination with relevant technical and compliance teams
Last Updated: September 2025
Effective Date: 15.09.2025
Version: 2.0 - AI Enhanced Privacy Policy
Appendix A: Third-Party Service Privacy Policies
Core AI and Infrastructure Providers:
- n8n.io Privacy Policy:https://n8n.io/legal/privacy/
- Hetzner Privacy Policy:https://www.hetzner.com/legal/privacy-policy
- OpenAI Privacy Policy:https://openai.com/policies/row-privacy-policy/
- Google Gemini Privacy Hub:https://support.google.com/gemini/answer/13594961?hl=en
Business and Analytics Tools:
- HubSpot Privacy Policy:https://legal.hubspot.com/privacy-policy
- Apollo.io Privacy Policy:https://www.apollo.io/privacy-policy
Payment and Communication Services:
- [Payment processor privacy policies to be added based on implementation]
- [Communication service privacy policies to be added based on services used]
Appendix B: Cookie and Tracking Technology Details
[Detailed cookie information table with categories, purposes, retention periods, and third-party details]
Appendix C: AI Model Technical Specifications
[Technical details about AI models used, their capabilities, limitations, and privacy-preserving features implemented]